Recently, the Ministry of Finance (MoF) launched the official webpage for e-Invoicing in the United Arab Emirates (UAE). The mandatory e-Invoicing regime will come into effect on July 1, 2026, for both business-to-business (B2B) and business-to-government (B2G) transactions.
Although many technical details are yet to be clarified, and further updates are anticipated in the coming months, now is the time to begin preparations. Several key areas warrant consideration well before the go-live date. For most of these topics, proactive steps may already be necessary, and waiting until the legislation is finalized could put your business at a disadvantage.
- Budget for Additional Costs
The UAE's e-Invoicing model follows the 5-corner Pan European Public Procurement On-line (PEPPOL). This model requires companies to connect through Accredited Service Providers (ASPs) which are technology vendors approved by UAE MoF. Unless your company becomes an ASP, you will need to onboard an external ASP. The external ASP will charge a software license fee, which may include a fixed annual component and an invoice volume-based component. Typically, configuration and potential system integration costs may also be incurred. It is therefore critical to budget for these unavoidable expenses early.
- Identify Stakeholders and Form a Project Group
E-Invoicing is not just a tax project. Digitizing the invoice flow is a large finance transformation project requiring a multi-disciplinary team from different departments (sales, procurement, finance, IT, and tax). No single stakeholder can drive this project independently. Forming a project group early ensures readiness and comprehensive buy-in across the organization.
- A Burden or an Opportunity?
While many may see e-Invoicing as a difficult challenge, it can also be a significant opportunity. Today, many invoices, especially on the purchase side, still have high processing costs with manual involvement. Whilst the focus is often on generating the e-invoice, it also presents an opportunity to automate the purchase side. As a tax department, you can play a proactive role in this, adding value to the business. When executed effectively, e-invoicing can become a cost-saving initiative rather than an additional expense.
- Ready to Share Your Data?
Once e-Invoicing is implemented, the Federal Tax Authority (FTA) will have visibility on all your transactions. With the rise of Artificial Intelligence and Machine Learning capabilities within tax authorities, it will become easier for auditors to review invoices comprehensively and detect any discrepancies. Consider your organization's readiness for this level of transperancy. Are you confident in the accuracy of your VAT data today? How many manual adjustments are currently made between month-end and the VAT return? With real-time invoice sharing, the opportunity for post-month-end adjustments will no longer be available.
- Review Your VAT Setup
If your answer to the above is "no", it may be preferable to begin a thorough review of your VAT configuration within your systems. Assess your master data, VAT determination logic, and configured tax codes to ensure all required fields for invoicing are accurately captured. If system updates are necessary, initiating this process early is essential, as change requests can be time-consuming and often compete with other IT priorities.
These points illustrate that while we are still waiting for legislation to be published, there are already several actions to consider and implement today.
Originally published 4 November 2024
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.